adjustment in the amount of paper currency tendered by Willard would have tacitly indicated that paper currency was valid (e.g., constitutionally issued). The decision is also notable for being the only one of four major Supreme Court decisions on equity which invoked the English common law roots of American equity jurisprudence. Even so, Justice Field never addressed the main point of English common law equity, which was to protect public interests. For many years, the Willard decision was the leading case in contract law regarding intent and enforcement. The case is still considered the leading decision on frustration of purpose regarding inflation in contracts. The Willard Court's conclusion that coin rather than paper currency be the form of payment (even though coin was no longer used) has drawn criticism from modern commentators, who found it inequitable. At least one modern commentator has characterized the decision "temporizing and cautious". Another has observed that the ruling never attempts to distinguish legitimate inflation from speculation or economic bubbles. The fact-specific nature of the Court-fashioned relief has also tended to limit the ruling's applicability. In part, this may be because modern contracts often require an independent re-appraisal of the land prior to sale. A 1978 United States district court case, Iowa Elec. Light & Power Co. v. Atlas Corp., 467 F. Supp. 129 (N.D. Iowa), has called into question the Supreme Court's assertion of discretion in equity cases, arguing that courts only have the ability to alter the time, place, and manner of payment and not the actual price. See also List of United States Supreme Court cases, volume 75 Knox v. Lee Legal Tender Cases References Bibliography Blue, Frederick J. Salmon P. Chase: A Life in Politics. Kent, Ohio: Kent State University Press, 1987. Burlingame, Michael. With Lincoln in the White House: Letters, Memoranda, and Other Writings of John G. Nicolay, 1860-1865. Carbondale, Ill.: SIU Press, 2006. Corbin, Arthur L. Corbin on Contracts. St. Paul, Minn.: West Publishing Co., 1964. Dawson, John P. "Judicial Revision of Frustrated Contracts: The United States." Boston University Law Review. 64:1 (January 1984). Dawson, John P. and Cooper, Frank E. "The Effect of Inflation on Private Contracts: United States, 1862-79." Michigan Law Review. 33:6 (1935). Denby, Elaine. Grand Hotels: Reality & Illusion. London: Reaktion Books, 1998. "Events Subsequent to the Contract As a Defence to Specific Performance." Columbia Law Review. May 1916. Fleming, John G. "The Impact of